Is a direct company SIPP contribution an allowable business expense?
Yes, provided the payment meets HMRC's "wholly and exclusively for the purposes of the trade" test. For a limited company director working outside IR35, a pension contribution to the director's SIPP is generally an allowable business expense, as confirmed in HMRC's Business Income Manual (BIM46035). The contribution reduces the company's taxable profit before Corporation Tax is calculated.
The contribution must be commercially justified, meaning it should be proportionate to the director's role and not excessive relative to market rates. HMRC can challenge contributions they consider uncommercially large. In practice, contributions in the range of what you'd expect to pay a director for their services are well within accepted limits. Consult your contractor accountant if you are making very large contributions in a single year.
